JUDGMENT - DAUD S.M., J.:---Is the timber imported by petitioner No. 1 into Bombay for the preparation of wooden containers for cables and wires manufactured by it "timber used for preparation of khokas only" leviable to octroi at 3% ad valorem vide Schedule H formulated under section 192 of the Bombay Municipal Corporation Act? 2. Petitioners plead that they import timber in the form of sleepers and planks for preparation of khokas. The khokas are containers being wooden boxes or cylindrical drums made up of different sizes and shapes for encasing cables and wires. The cables and wires are manufactured by the petitioners and are packed into the containers aforementioned. The containers or khokas are manufactured by the petitioners in its carpentry section---the size and shape depending upon the orders received from customers. The timber imported for the manufacture of khokas is generally Assam Pine or Devdar. The said species of timber is then taken into the carpentry section of the petitioners where it is utilised for the preparation of drums round which the wires and cables manufactured are rolled. Thereafter, the exterior is covered by planks which are nailed. Respondents (BMC) insisted on denying to the petitioners the benefit of the concessional charge of 3% prescribed by Entry 30 in Schedule H. This denial is unjustified and contrary to the true intendment of the entry. According to the petitioners, timber includes every kind of wood used in building or carpentry. Khoka is not an English word but is used in common parlance to denote any container capable of packing anything or containing a cavity to accommodate or place something within it in such a way, that the thing accommodated or put in, can safely be lifted, transported, and/or transferred from one place to another without any inconvenience or causing of damage to the thing accommodated or put therein. In common parlance khoka would mean any packing article made either out of timber or paper or hardboard. It can come in any shape circular, rectangular or square etc. and in the form of drums or boxes. Petitioners use the timber imported to prepare khokas of all the three shapes mentioned above. Generally when the boxes are to be used for packing of cables and wires, the khokas are circular in shape. It can come in any shape circular, rectangular or square etc. and in the form of drums or boxes. Petitioners use the timber imported to prepare khokas of all the three shapes mentioned above. Generally when the boxes are to be used for packing of cables and wires, the khokas are circular in shape. This is not because of any grade compulsion, but because heavy cables and wires cannot be stored or packed into rectangular or square boxes. Also difficult is it to bring out the cables or wires from the boxes of shape other than circular. Circular drums are used because the cables and drums are heavy and unfoldable and have to be used immediately they are brought out of the drum. This would not have any bearing on the nomenclature to be given to the container. The drum or box whatever be its shape or size, is a khoka and therefore, entitled to the concessional rate for levy of octroi. 3. The BMC has not filed a return. But Counsel representing it contends that the word khoka has a distinct connotation. It is a wooden container, either rectangular or squarish in shape. The wood that goes into the making of khoka is of an inferior quality and of little use after the commodity packed therein is removed, except as a container again. Having regard to the quality of the timber used, the containers manufactured by the 1st petitioner cannot be conceived of as khokas in any sense in which that expression is understood in the market. It is the commercial understanding of the word which should govern judicial interpretation thereof. Seen thus, the BMC has rightly declined to treat the timber imported by the petitioners as a timber used for the manufacture of khoka only. 4. Entry No. 30 has to be set out in full so as to appreciate the true intention of the legislature. The said entry appears in Clause IV which is titled as "Articles used in construction of buildings, roads and other structures and articles made of wood or cane". The entry itself is thus:--- "30. Timber, ballies, cane and 6 per cent ad valorem articles made of any of them, doors (3 per cent ad valorem windows, frames, furniture, pets, for timber used for staircases, sandal wood and preparation of articles made of such wood. khokas only)". The entry itself is thus:--- "30. Timber, ballies, cane and 6 per cent ad valorem articles made of any of them, doors (3 per cent ad valorem windows, frames, furniture, pets, for timber used for staircases, sandal wood and preparation of articles made of such wood. khokas only)". From the above the position emerging is that there are different kinds of timber contemplated by the entry and that a concessional rate is given to that timber which is used in the preparation of khokas only. In other words, the legislature wanted to distinguish between timber and timber. The superior variety was to be assessed to octroi of 6% ad valorem. There was an inferior variety and it could be used only for preparation of khokas. Timber of this inferior variety was to be subjected to octroi at 3% ad valorem. The word khoka is a vernacular word and well understood, not only by the mercantile class, but by the people in general. The article is made of wood and is used for packing of articles. This is to enable protection to the packed article against pilferage and the ravages of nature and handling. The wood employed for the preparation of khokas may differ, in that it may come from different trees. Nonetheless, one characteristic common to all khokas is that they are made of wood of inferior types. Its life is not much and a khoka can be recyled only for use in the same manner i.e. as a khoka. Factors of economy and scarcity may compel certain classes of people to use parts of khoka for housing, shelter and also as fuel. All said and done, this is because timber used in the preparation of khokas is of an inferior type and therefore, inexpensive. In a sense the petitioners not wrong in contending that the containers prepared for packing or inserting cables and wires and khokas. But timber used in the preparation of petitioners' khokas is not of the inferior or inexpensive kind. On their own showing the petitioners import two species of wood, viz. Assam Pines or Deodar for manufacturing of khokas. They are used for packing their cables and wires. Learned Counsel representing the BMC has made available extracts from the Encyclopaedia Britannica, 14th edition. On their own showing the petitioners import two species of wood, viz. Assam Pines or Deodar for manufacturing of khokas. They are used for packing their cables and wires. Learned Counsel representing the BMC has made available extracts from the Encyclopaedia Britannica, 14th edition. Deodar in that Encyclopaedia is explained as follows:- "The deodar or god tree (Cedrus Deodara) is a species of coniferous evergreen tree closely allied to the cedar, the timber obtained therefrom being of considerable value........... The wood is durable and light-red in colour and is used particularly for cabinet work as it can be highly polished." Pine is to be found under the heading 'Fir' and is described thus :- "......sometimes employed as a general term for the whole of the true conifers........ Their cones are composed of thin, rounded, closely embricated scales, each with a more or less conspicuous bract springing from the base. The trees have usually a straight trunk, and a tendency to a conical or pyramidal growth....... There are about 25 species of the true fir........ The silver fir, a representative world species is as many as 150' height large spreading horizontal curving upward......... The wood is inferior, but soft and easily worked, is largely employed in the countries to which it is indigenous for all the purposes of carpentry." It is not possible to conceive of either Deodar or Pine trees as a source for that timber which is used in the preparation of khokas commonly understood. It is well-settled that words and expressions appearing in a taxation statute have to be given their meanings as understood by those who deal with articles answering to the said words and expressions. Khokas as commonly understood are wooden containers, the wood being of inferior variety and not costing much. The timber that petitioners import for the manufacture of its khokas is of a superior variety and the containers manufactured by the petitioners are khoka in a very sophisticated sense. The common man and certainly the commercial world will not apply the word 'khoka' to the product manufactured by the petitioners. In the result, the petition fails and the Rule is hereby discharged with parties being left to bear their own costs. Petition dismissed. -----